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ARTICLE · 30 SEPTEMBER 2025

EPA Initiates "Take 3" On The Toxic Substances Control Act Risk Evaluation Framework Rule

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As covered in a previous Holland & Knight alert, the 2016 amendments to the Toxic Substances Control Act (TSCA) required the U.S. Environmental Protection Agency (EPA) to establish a regulatory process for evaluating...

United StatesEnvironment
Michal I. Freedhoff
Michal I. Freedhoff
Meaghan Hembree
Meaghan Hembree
Dimitrios Karakitsos
Dimitrios Karakitsos
Amy O'Brien
Amy O'Brien
Halley Townsend
Halley Townsend
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Highlights

  • The U.S. Environmental Protection Agency (EPA) published a Notice of Proposed Rulemaking (Proposed Rule) on Sept. 23, 2025, to amend the 2024 Toxic Substances Control Act (TSCA) Risk Evaluation Framework Rule (Framework Rule), a foundational rule that governs the agency's process for evaluating risks of existing chemical substances. Public comments on the Proposed Rule are being accepted until Nov. 7, 2025.
  • The Proposed Rule seeks to reverse several policies codified in the Biden-era 2024 Framework Rule, reinstating approaches from the first Trump EPA 2017 Framework Rule, including requiring risk determinations for each condition of use, removing requirements to evaluate all conditions of use or exposure pathways, and changes to how personal protective equipment (PPE) is considered.

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